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Mandatory Training in General Practice
- What training is mandatory for practice staff?
- Does your practice have a list of what it considers to be mandatory training for staff?
- Who really knows what training is mandatory?
- What new mandatory training is on the horizon?
- The CQC does not have a definitive list of mandatory training.
Nigel’s Surgery 70
This CQC mythbuster – a website with clear guidance on a wide variety of general practice topics - states:
CQC does not have a list of mandatory training for members of the GP practice team. This is because exact training requirements will depend on the role and specific responsibilities of practices and the needs of the people using the service. Ultimately the practice is responsible for determining what mandatory, and additional, training staff need to meet the needs of their patients.
The mythbuster goes on to say:
Key line of enquiry (KLOE) E3 specifically considers whether “staff have the skills, knowledge and experience to deliver effective care and treatment”. All providers are required, under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 to meet Regulation 18. Providers must have sufficient numbers of suitably qualified, competent, skilled and experienced staff to meet the needs of the people using the service at all times.
So, to sum up, practices need to decide what training is mandatory to meet this regulation based on the staff roles and needs.
Having a clear training matrix/table for completed staff training and when training is due cannot only be helpful for you but also for inspections.
A good system may be to have staff names down the side of a spreadsheet document or in a table, each item of training that your practice deems to be mandatory along the top to head each column, and information in the table about when each member of staff last attended the training. Colour-coding using the traffic light system is also a good idea – a green-filled box for staff who have recently had their training or are not due anytime soon, a yellow-filled box for any staff who have less than 6 months until their training needs renewing and a red-filled box for any staff that are very close to deadline or who are overdue.
You may have already had a CQC Inspection, but there are still a good number of practices who haven’t. Training still needs to be kept up to date on an ongoing basis as this will still need to be evidenced in future years, to ensure you continue to meet regulation 18.
Information Governance – just one of the areas of mandatory training that is very important
Information Governance, Data Security and Confidentiality is not mentioned in the mythbuster, but we need to ensure this is mandatory for new and existing staff. This should be undertaken on an annual basis to ensure all staff are up to date with new and existing guidelines.
The 2016/17 General Medical Services (GMS) contract, which is 46 pages long, includes a small paragraph that can easily be missed on the area of Information Governance.
‘Information governance NHS England and GPC will continue to promote the completion of the HSCIC information governance toolkit, including adherence to the requirements outlined within it. Practices will also continue under the GMS Regulations to nominate a person with responsibility for practices and procedures relating to the confidentiality of personal data. With the sheer volume of patient information that a GP practice handles, it is vital that practices can handle information confidentially and securely and that they can demonstrate this. Practices should also be cognisant of the National Data Security Review recommendations that will outline a set of recommendations and data security standards including the potential subsequent iteration of the IG toolkit’.
The crucial part is being aware of the National Data Security Review Recommendations. This can have a big impact on your practice’s policy and procedures, and could mean additional training is needed to add to your mandatory training matrix.
If you have not yet seen this report then it is worth a read. There were 22 practices and 18 NHS trusts that were involved in the CQC report.
There were 6 recommendations on the CQC report that was referred to in the above document, including one that refers to mandatory training:
‘Staff should universally have access to the “right information, tools, training and support”, including mandatory and regularly refreshed training on data security. Staff should all be provided with effective guidance on how to raise concerns about potential breaches. An updated Information Governance Toolkit should enable HSCIC and NHS England to identify providers in need of support. Local and regional data sharing should be underpinned by common procedures’.
Another one of the recommendations is referring to your practice’s policies and procedures:
‘Systems and protocols need to be developed with the needs of patients and staff at the forefront. All organisations are urged to undertake a “comprehensive review” of existing arrangements for managing patient data, which would in turn “inform a strategy to simplify and clarify” systems. Moreover staff should be involved in the planning of new or replacement systems and organisations should produce a clear plan for managing transitions from old to new. Procurement should be in line with common standards’.
Your updated policy and procedure could be linked to the mandatory training. The CQC say they plan to amend their framework for inspections, so even if you have had an inspection, this is something that will be used for future inspections too.
‘CQC will amend its inspection framework in order to take greater account of information governance and to seek assurance around internal and external validation against the standards’.
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